The French Law Practice is dedicated to international private clients dealing with France and the UK


The end of French social contributions for non-residents?

The European Court of Justice has just rendered a very positive decision that will impact the application of French Social contributions to non-French residents owning French real estate.

Draft legislation on fight against fraud and tax evasions: update on impacts for Trustees

The Finance Act 2011 introduced a tough taxation regime for foreign trusts having French connections together with potentially wider ranging tax and reporting obligations imposed personally on trustees.


The French rules apply to all Trusts:

  • Where any of the settlor, deemed settlor or beneficiary is a French tax resident.
  • Or where the trustees hold certain French situs assets, even if the settlor, deemed settlor or beneficiary is not a French tax resident.


New deadline of 30 September 2012 for the Trustees disclosure obligations and the sui generis levy of 0.5%

The first rectified Finance Act for 2011 introduced a new penalizing regime of taxation for foreign Trusts in France.


The French Tax Authorities (FTA) have now published their Decree (dated 15 September) providing a new deadline for 2012 in respect of (1) the Trustees disclosure information obligation at the creation, amendment or extinction of the Trust and of (2) the annual disclosure information.


Deadline of 15 June 2013 for the Trustees annual reporting obligation

 The first rectified Finance Act for 2011 dated 29th July 2011 (entry in force 31th July 2011) introduced a new penalizing regime of taxation for foreign Trusts in France, and new reporting obligations for the Trustees.

The Trustees have until 15 June 2013 to make their annual disclosure of the market value of the assets, rights or income capitalised in Trust.  This reporting obligation applies to Trusts in existence on 1st January 2013.

The French Law Practice dans l'Agefi Actifs

Dans son dossier spécial Expatriation fiscale, l'Agefi Actifs présente les condéquences d'une expatriation vers la Suisse, la Belgique ou le

Royaume-Uni. Caroline Cohen y livre un entretien..

These publications are intended to provide general information and guidance only and are not intended to provide advice to any specific person.

You are recommended to seek professional advice before taking or refraining from taking any actions based on the contents of these publications.

Tax law is subject to change.